Title
Bayog vs. Natino
Case
G.R. No. 118691
Decision Date
Jul 5, 1996
A landowner-lessor filed an ejectment case against a tenant-lessee, but the Supreme Court ruled the MCTC lacked jurisdiction due to the tenancy relationship, annulling the ejectment and demolition orders.
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Case Digest (G.R. No. 118691)

Facts:

Agricultural Leasehold Contract: On 16 June 1973, petitioner Alejandro Bayog (BAYOG) and private respondent Alberto Magdato (MAGDATO) entered into an Agricultural Leasehold Contract over a 0.8-hectare lot in Centro Pojo, Bugasong, Antique. BAYOG was the landowner-lessor, and MAGDATO was the tenant-lessee. The contract commenced in the crop year 1975-1976 and was governed by R.A. No. 3344, as amended.

Certificate of Agricultural Leasehold: On 19 April 1983, then President Ferdinand E. Marcos issued a Certificate of Agricultural Leasehold to MAGDATO, confirming his status as an agricultural lessee. The certificate granted MAGDATO rights, including protection against ejectment, peaceful possession, and cultivation of the land.

Deed of Equitable Mortgage: On 3 September 1990, BAYOG executed a Deed of Equitable Mortgage in favor of Santiago Pesayco for P250,000.00, covering four parcels of riceland.

Ejectment Case: On 26 November 1992, BAYOG and Jorge Pesayco, Jr. filed a complaint for ejectment against MAGDATO before the Third MCTC of Patnongon-Bugasong-Valderama, Antique, alleging MAGDATO’s house obstructed cultivation. MAGDATO filed his Answer late, admitting BAYOG’s ownership but claiming he was a tenant with rights under the leasehold contract and certificate.

MCTC Judgment: The MCTC ruled in favor of BAYOG and Pesayco, ordering MAGDATO’s ejectment and the demolition of his house. The judgment was executed, and MAGDATO’s house was demolished on 24 January 1994.

Petition for Relief from Judgment: On 9 February 1994, MAGDATO filed a petition for relief from judgment with the RTC, alleging excusable neglect due to illness and illiteracy. The RTC set aside the MCTC judgment and remanded the case to the MCTC.

Issue:

  1. Whether the petition for relief from judgment is prohibited under the Revised Rule on Summary Procedure.
  2. Whether the MCTC had jurisdiction over the ejectment case, given the alleged tenancy relationship between BAYOG and MAGDATO.
  3. Whether MAGDATO’s petition for relief from judgment was filed within the reglementary period.
  4. Whether the MCTC’s orders for demolition and ejectment were valid.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Additional Rulings

The Supreme Court directed Judge Deogracias K. del Rosario and Atty. Marcelo C. Josue to show cause for gross ignorance of the law and violation of the Code of Professional Responsibility, respectively.


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